Life Science Compliance Update

October

2016

NPAs and DPAs – An Enforcement Loophole or Compliance Incentive?

Written by , Posted in Enforcement

Robert N. Wilkey, Esq., Staff Writer for Life Science Compliance Update

The U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (“SEC”) recently have faced criticism for their use of Deferred Prosecution Agreements (“DPAs”) and Non-Prosecution Agreements (“NPAs”). Given that DPAs and NPAs are subject to little or no judicial scrutiny or involvement, critics are increasingly viewing them as compliance and enforcement loopholes, where life science compliance industry can circumvent DOJ prosecution.


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